Corporate Governance

Ethics & Compliance

At Booz Allen, our commitment to operating with the highest ethical standards goes hand-in-hand with our purpose and values. Our Code of Business Ethics and Conduct describes how we put our ethical standards, values, and purpose into action. Together they guide our firm and inform how we collaborate with our clients, competitors and partners, and other external stakeholders.

Our Ethics & Compliance program helps our people understand their important role and responsibilities in creating our culture of integrity. It provides leadership and establishes rules around how we, as a firm, strive to do what is right while operating our business in compliance with laws and regulations including laws governing anticorruption, competition, data privacy, ethics, and international trade compliance. The program is anchored by key controls and processes, driven by our risk management mission, and supported by the effort we invest in monitoring our risks and controls. Our Chief Ethics & Compliance Officer leads the program, and, along with a team of ethics and compliance professionals, receives oversight and guidance from our executive-level Ethics & Compliance Committee and the Board of Directors' Audit Committee.

To help ensure our people have the information they need to live our value of ferocious integrity, we use firmwide trainings and awareness-building campaigns to help keep important ethics and compliance topics top of mind. We regularly survey our people to help ensure our people understand and embrace our ethics and compliance initiatives and to receive pointed feedback on how we can make our program even more useful and effective as we move forward operating in an always-evolving regulatory environment. We also host an annual Ethics & Compliance Week, which has included panels of firm leaders speaking on the importance of operating with integrity along with leaders from our Investigative team driving greater transparency by speaking about our investigations process and internal system of organizational justice. Our Compliance Analytics function ensures we are using data to inform our risk assessment process, strategic planning efforts, and to operate our Ethics & Compliance programs.

Mandatory Training

We require firmwide annual Ethics & Compliance training to help guide employees and provide them with the information needed to live our purpose and values and to adhere to our Code of Business Ethics and Conduct. Additional role-based training is required of some employees, such as those who handle certain types of information or serve as career managers. The firmwide training covers a variety of risk-based focus areas such as Data Privacy and Protection, Information Security, Competition, Anti-corruption, Organizational Conflicts of Interest, and Intellectual Property.

Our Commitment to Non-Retaliation

We rely on all Booz Allen employees to promptly escalate concerns about our firm's business or business practices. We provide multiple avenues for our people to do so including our Ethics Helpline, which is always available and provides the option to report issues anonymously. We have a network of more than 100 employees serving as Ethics Advisors, another firm reporting channel, so employees who wish to report something to someone outside of their management chain and the Legal, Ethics & Compliance function have a resource available to them. Our Ethics Helpline is also available to our suppliers, clients, and the general public to allow these parties to also report concerns. Every report is evaluated and, if appropriate, investigated by our Legal Investigations and/or Employee Relations teams. Booz Allen strictly prohibits retaliation against anyone that raises a concern in good faith. The Ethics Champion award, one of the highest awards Booz Allen offers employees, showcases employees living our value of ferocious integrity through their words and actions.

Technology-Powered Continuous Monitoring

We use technology to enhance our Ethics & Compliance program. Over the past year, we have implemented several new technology solutions including a new integrated Ethics Helpline and Investigations Case Management System, a Conflict of Interest Disclosure Management System, and a Third Party Risk Management System. These new systems help to provide us with greater data-driven insights and align with our continuous improvement mindset of operating our program.

Looking ahead, we will continue to evolve our program to align with our ongoing organizational transformation and changes in the regulatory environment. This includes robust and clear policies to drive desired employee behaviors, targeted and content-driven training and communications, an increased focus on transparency, and maturing our practices related to our third-party ecosystem.